How Much Does Clean Cost?

Published in the Cascadia Weekly on 10/28/06

The North Sound Baykeeper and RE Sources are calling for a prudent and protective cleanup in the Whatcom Waterway and ASB.  Unfortunately, the Washington State Department of Ecology (Ecology) is not.

In their recently-released Remedial Investigation/ Feasibility Study (RI/FS) Ecology proposes a cleanup that relies on capping much of the Whatcom Waterway, dredging the Waterway where needed for navigation, and dredging the ASB in preparation for its conversion into a marina.   We’d like to see a different scenario; one that includes dredging of all contamination, where it exists above Ecology’s “Minimum Cleanup Level,” in both the Waterway and ASB.

You might be asking, “Why would Ecology, the state agency responsible for protecting our natural resources, propose a clean-up that is not the most protective?”  The reason: cost. Capping sediments costs much less than removing them. The estimated cost of Ecology’s preferred remedy is $44 million; whereas RE Sources’ plan would cost at least twice as much, probably more.

The dramatic cost of removing the mercury has forced Ecology’s hand, to some degree, as they are legally obligated to choose a cleanup remedy that is permanent to the “maximum extent practicable.”

This means the cost should be as low as possible, while still meeting the legal requirements for cleanup: protectiveness, permanence, long-term effectiveness, short-term risk management, ability to implement, and consideration of public concerns.

The balancing act between cost and the above-mentioned legal requirements is weighed using a “disproportionate cost analysis,” which examines whether the benefits of each more costly alternative are proportionate to its higher cost.

In the case of the Whatcom Waterway cleanup, Ecology says the higher cost associated with removing mercury is disproportionate to the benefits such removal would achieve. We disagree.  

In the disproportionate cost analysis, Ecology assumes that capping sediments is equally protective to removing them. Under this assumption, it makes more sense to cap the contamination rather than remove it, since capping is cheaper, and in Ecology’s opinion, provides little to no added benefit.

We believe Ecology’s assumption about the protectiveness of capping is faulty and that, over the long term, removal of contaminated sediments is more protective than leaving them in place. The Ecology evaluation does not adequately account for contaminated sediment re-exposure, during a heavy storm event or under prolonged erosional activity. Additionally, the potential movement of mercury upwards, from deeper buried sediments, has still not been adequately characterized, and is a risk.

Also included in the disproportionate analysis is an evaluation of short term risk, or the risk of contamination exposure through cleanup actions. We acknowledge there is a somewhat higher short-term risk and greater likelihood of stirring up contaminated sediments during sediment removal and dredging. However, we believe cleanup actions should be taken with the long-term risk in mind, while working to minimize any short-term risk.

Finally, the disproportionate cost analysis does not take into account the real issue of the impairment of each person, bird or fish that might be affected by mercury left in the bay.  Mercury, a known neurotoxin, affects the brain development of fetuses and the young. It can result in decreased IQ, memory, language, and fine motor abilities in people. Early exposures to methylmercury contribute to loss of intelligence in people, and in monetary terms, the lost productivity amounts to $8.7 billion per year, nationally.   In fish and birds, mercury can impair foraging and nesting behaviors.

At the end of the day, capping mercury in Bellingham Bay does not pass muster in a disproportionate cost analysis. In fact the real cost of cleanup cannot even be accurately evaluated: We do not know exactly what will happen if we leave the mercury in place.  We don’t know how much mercury will be released if a cap fails.  And we don’t know how many and to what extent, children or fish or birds will be affected if this mercury finds its way back into the food chain.  What we do know, however, is the risk of recontamination is significantly less if the bulk of mercury contamination is removed from the bay.   For that reason, RE Sources and the North Sound Baykeeper want the mercury removed.

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